August 2012
PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK U.S. DEPARTMENT OF THE TREASURY
Good afternoon. I felt it was of critical importance for me to be here today, particularly considering the timing of your conference. On April 16 of this year, FinCEN’s regulations requiring non-bank residential mortgage lenders and originators (RMLOs) to establish Anti-Money Laundering programs (AML) and file Suspicious Activity Reports (SARs)1went into effect. And the compliance deadline was just this Monday, August 13, 2012.
Compliance Obligations of Certain Loan or Finance Company Affiliates of Federally Regulated Banks and Other Financial Institutions
The Financial Crimes Enforcement Network ("FinCEN") is issuing this Ruling to clarify the requirements under FinCEN's regulations for loan and finance companies that are subsidiaries of financial institutions subject to the same regulations applicable to the parent financial institution and examinations of a Federal functional regulator for compliance with the anti-money laundering and counter-terrorist financing obligations under the laws generally known as the Bank Secrecy Act ("BSA").1 FinCEN hereby determines that a loan or finance company that: 1) is a subsidia